Slavitt Names ICD-10 Ombudsman, Officials Tackle ICD-10 Q&A
By - Last Thursday’s “Countdown to ICD-10” MLN National Provider Call – featuring Andy Slavitt, Acting Administrator of the Centers for Medicare & Medicaid Services (CMS), Sue Bowman, Senior Director of Coding Policy and Compliance at the American Health Information Management Association (AHIMA), and Nelly Leon-Chisen, Director of Coding and Classification at the American Hospital Association (AHA), and other officials – aimed to educate and update the healthcare industry about ICD-10 implementation. Time is of the essence as the one-month ICD-10 countdown is just around the bend.
Slavitt announces ICD-10 ombudsman as finish line nears
Slavitt provided the call’s opening comments with a national ICD-10 implementation update confirming the naming of an official ICD-10 ombudsman, William Rogers, MD, CMS’s Director of the Physicians Regulatory Issues Team. This announcement is part of CMS’s deal with the American Medical Association (AMA) to avoid financial disruption for the healthcare industry following October 1. As RevCycleIntelligence.com reported, CMS was urged to appoint an ombudsman “as soon as possible.”
In reference to the healthcare community’s years of investment as the October 1 implementation deadline nears, Slavitt said, “I will be paying personal attention to everything that happens between now and after our launch.” He additionally explained CMS will not accept ICD-9 codes for dates of service after September 30 and will not accept claims with both ICD-9 and ICD-10 codes once implementation begins.
Highlights from the MLN call’s Q&A commentary
Some questions asked during the Q&A session conducted at the final section of the “Countdown to ICD-10” MLN National Provider Call” were described from officials as being too “hypothetical” to clearly answer without access to a medical record that could perhaps more clearly illustrate a particularly challenging issue. Nonetheless, the following is a brief summary of selected ICD-10 questions and their corresponding answers.
One caller asked what available tools might help radiologists address specificity issues with their reports. Officials responded by clarifying that specific answers are not listed on the CMS website and advised reaching out to a specialty society. (Perhaps a lack of available information regarding this question is problematic. As RevCycleIntelligence.com recently reported, radiologists can expect an “enormous” financial impact come October 1.)
Another caller asked for clarification about how initial A and subsequent B encounter codes relate to physical and occupational therapy, especially regarding direct access and a referred patient. Said the caller, “It seems intuitive that if they’re a direct access patient seen for the first time, they would be coded as an 'initial.' If it’s an injury and they’re referred, one would think it’s 'subsequent.' I’m hearing two different sides of that story.”
In response, Leon-Chisen replied the answer to such is variable. “If direct access means going right to physical therapy and not being referred by a physician, that would be where patients receive treatment as an 'initial' encounter,” Leon-Chisen stated. “Usually, if someone has already gone through the physician, perhaps they’ve had something already addressed, then the physical therapy could be a 'subsequent' encounter,” she added, maintaining the seven characters are based on active treatment being provided.
Another called asked for a clear definition of “active treatment” while struggling to differentiate if it involves the healthcare provider, active versus healing, or a "subsequent" recovery phase. Responded Leon-Chisen, “There is no specific hard-set definition of what treatment is. Some examples are given in the official guidelines such as surgical treatment, emergency department encounter. It’s not an all-exhaustive list. But what is clearer for the 'subsequent' encounters, usually those are where there’s routine healing or a problem with the healing.”
Subsequently added Bowman regarding some of the types of questions being asked thus far and their inability to be successfully answered, “It will be difficult for us to answer specific coding questions on today’s call due to issues with needing the medical record. We’re getting into a lot of technical issues that may not be helpful for the rest of the audience.”
Another caller subsequently asked, “During the transition period, if you feel a provider has used a diagnosis code that’s not completely correct, will you be sending any sort of a message back to the EOB, kind of like what you did with electronic prescribing (eRx)?” Officials responded there are no plans to provide any special messaging of this kind.
Asked a caller who worked in a skilled nursing facility, “In converting ICD-9 to ICD-10, PT, OT, and ST all have the same diagnosis code and I don’t know how to differentiate.” Replied Leon-Chisen, “You still have your CPT codes to actually describe the service. Those are not going away. While the diagnosis code many be similar because two different types of therapy are being provided for the same condition, that’s not something to worry about because the CPT codes will identify the differences in the services.”
Another caller confirmed concern about the anticipated backlog of claims and asked for an estimation of turnaround time regarding significant claims reimbursement delays. Replied Felicia Rowe, CMS’s Health Insurance Specialist Provider Billing Group Center for Medicare, there is a standard turnaround time for the payment of Medicare claims – 14 days for electronic claims and 9 for paper. “We don’t anticipate there being any impact on payment,” Rowe stated.
Asked a Part B provider in reference to the submission of a service to a physician, “One of our physicians sees patients in the hospital. So if the patient was seen on the hospital on September 28 and 29, let’s say, but discharged after October 1, are we required to use ICD-9 or ICD-10?” According to the response, the caller was advised to select the correct code set for physician claims based on the “from” date of service on a claim. If billing is for a hospital visit, the caller was also advised to select the code for the date of service for a particular visit.
In response to another question, it was confirmed that the “x” place holders for ICD-10-CM codes where a seventh character is applied but the base code is less than 6 characters are indeed going to be used, since the seventh character has to be in the seventh character position.
Asked an individual who worked for a surgical center which uses EOBs for charge specificity, "Although new forms are needed for physicians, is such applicable to a surgery center?" Answered Rowe, “The forms are not changing as a result of the transition.”
Regarding a question about ICD-10 diagnosis codes involving the left and right sides of the body, another caller wanted to know if while trying to bill something that involves both the left and right sides, if such information is doubly listed on a claim, with the use of modifiers. The response was that a modifier is required for laterality and that there will not be audits if you stay within the same family of codes.
Officials ended the call by confirming within the first year of ICD-10 implementation, misunderstanding is to be expected as troubles arise.
